ENSSER letter to Belgian governments regarding NGMT deregulation

In the negotiations about the EU Commission’s 2023 proposal for deregulating the new genetic modification techniques (NGMTs), the EU Council is taking a long time to come to an agreement with a qualified majority of member states. Currently the Polish Presidency of the Council has suggested new amendments to the proposal, and the vote of Belgium seems to be relevant to allow a decision. ENSSER has therefore written this letter to some of the Belgian governments, namely the Federal, Flemish and Brussels governments.

The letter reads as follows:

New Genetic Modification Techniques (NGMTs) – Deregulation proposal of EU Commission

Dear Ministers and experts,

In view of the new Polish proposal to the EU Council concerning the European Commission’s 2023 proposal to deregulate the new genetic modification techniques (NGMTs), ENSSER would like to share its serious concerns about this proposal and to ask you to abstain from supporting, if not to reject this proposal.

ENSSER, the European Network of Scientists for Social and Environmental Responsibility, has a long-standing expertise in the field of genetic modification, risk assessment and environmental impacts of novel technologies.

From our perspective, it is not scientifically justifiable to exclude a whole range of genetically modified organisms (GMOs) from the EU’s requirements for GMO risk assessment, traceability and labelling. These organisms carry potential risks for the environment, biodiversity and sustainable agriculture as well as for human and animal health. We have argued this in our 2023 statement about the proposal. In short:

– The claim that some GM plants produced through new GM techniques (NGMTs) are equivalent to conventionally bred plants is not based on science. The proposed criteria to establish such equivalence (Annex I of the proposal) are arbitrary.
– There is no relationship between the proposed equivalence criteria and the associated risks. Thus, the equivalence criteria bear no relationship to the safety of the NGMT plants concerned.
– NGMTs can achieve deep and far-reaching changes in a plant – changes that are not possible with conventional breeding. They can radically change a plant’s biochemical pathways and composition – intentionally and unintentionally.
– None of the amendments discussed among the member states (nor indeed the amendments which the EU Parliament has suggested) repair the above-mentioned shortcomings of the proposal.
– Risk assessment, traceability and labelling are all important to protect the environment and human health. Safety issues that were not identified in pre-market risk assessment can become apparent after commercialisation. Traceability and labelling help to identify and analyse these issues and withdraw unsafe products from the market.
– According to legal expertise, the current EC proposal is also in breach of the Cartagena Protocol on Biosafety, which in turn holds the risk of resulting in serious economic and trade consequences.

We therefore ask you to at least abstain from supporting the EC proposal (in the current Polish form or any other form), and preferably to reject the proposal altogether.

The existing EU legislation on genetically modified organisms (GMOs) serves its purpose and must be maintained for the new GM techniques, just as for the older ones. If the deregulation proposal is accepted, the EU will put the environment, biodiversity, sustainable agriculture and human and animal health at risk.

Please do not hesitate to contact us with any questions you may have.

Best regards,
Prof. Neni Nicolopoulou-Stamati Chairperson of ENSSER
For further information, please contact: Dr. Ricarda Steinbrecher
Developmental biologist and molecular geneticist Board member of ENSSER
+44 7769 733594